The characterization came in a report the FTC published as part of an appropriations measure.

The Durbin amendment capped the amount of interchange that debit card issuers of over $10 billion can receive for transactions cardholders validate with a personal identification number.

The measure exempted smaller financial institutions, including most credit unions, from the cap but also mandated changes to the number of debit transaction processing networks which all financial institutions must use.

CUNA took issue with commission's report, arguing that it only briefly touched on the impact the cap was having on credit unions and asserting the FTC drew only on “selective information” from reports generated by the Federal Reserve and the Government Accountability Office.

“The FTC’s study does not include significant information from the GAO report that helps to present a more complete assessment of the impact of Section 1075 on credit unions and small banks,” CUNA wrote, pointing out that the GAO had documented a decline in credit union debit card interchange of about 5% and that it had explicitly left open the possibility of further declines in the future.

“The agency’s report should have noted that additional data reflects recent declines in interchange fee income, particularly for PIN transactions,” CUNA contended. “Also, it should have acknowledged that it is very early in the implementation of Section 1075 and that further data, as the Federal Reserve Board intends to provide on an annual basis, is needed to present a balanced assessment of the impact of Section 1075 on credit unions and small banks.”